LightGuide, Inc. v. Amazon.Com, Inc., et al

On November 7, 2022, LightGuide, Inc. (“Plaintiff”), represented by Andrea L. Fair, Claire A. Henry, Garrett C. Parish, and Johnny Ward, Jr. of Ward, Smith & Hill PLLC and Andres C. Healy and Matthew R. Berry of Susman Godfrey LLP, filed an intellectual property lawsuit against Amazon.com, Inc. and Amazon.com Services LLC (collectively “Defendants” or “Amazon”), seeking declaratory and injunctive relief for alleged infringement of the U.S. patents owned by the plaintiff. This case was filed in the U.S. District Court for the Eastern District of Texas with Judges Robert W. Schroeder, III and Roy S. Payne presiding. 

The plaintiff filed the complaint for alleged infringement of the U.S. Patent No. 7,515,981 (the “’981 Patent”), U.S. Patent No. 9,658,614 (the “’614 Patent”), and U.S. Patent No. 10,528,036 (the “’036 Patent”) (collectively, the “Asserted Patents”) owned by the plaintiff. 

In the complaint, the plaintiff claimed, “LightGuide is the owner of all rights, title, and interest in and to United States Patent No. 7,515,981 (the ‘’981 Patent’), United States Patent No. 9,658,614 (the ‘’614 Patent’), and United States Patent No. 10,528,036 (the ‘’036 Patent’) (collectively, the ‘Asserted Patents’).”

Plaintiff then alleged, “Amazon has willfully infringed and continues to willfully infringe at least claim 12 of the ’981 Patent in violation of 35 U.S.C. § 271, either literally or through the doctrine of equivalents, by making, using, selling, or offering for sale in the United States, and/or importing into the United States, without authorization, systems and methods that practice at least claim 12 of the ’981 Patent, including by committing acts of infringement in this District. Amazon is liable for its infringement of the ’981 Patent pursuant to at least 35 U.S.C. § 271(a), (c), (d) and/or (f).”

Plaintiff further alleged that “Amazon makes, uses, sells, offers for sale, imports into the United States, and/or supplies or causes to be supplied from the United States, light guided operational guide systems, which infringe at least claim 12 of the ’981 patent.”

Plaintiff also alleged, “Amazon committed and is committing the foregoing infringing activities without license from LightGuide. Amazon’s acts of infringement have damaged and irreparably harmed LightGuide, as owner and assignee of the ’981 Patent.”

The plaintiff further alleged, “Amazon has had actual knowledge of the ’981 Patent since no later than September 2016. Amazon’s continued infringement, despite its knowledge that it infringes the ’981 Patent, is intentional, deliberate, willful, and characteristic of a pirate.”

Plaintiff then alleged that “Amazon has infringed and continues to infringe the ’981 Patent in violation of 35 U.S.C. § 271(f) by, for example, supplying or causing to be supplied in or from the United States all or a substantial portion of the components of the operational guide systems claimed in the ’981 Patent, where such components are uncombined in whole or in part, in such manner as to actively induce the combination of such components outside of the United States.”

The plaintiff also alleged that “Amazon is liable for infringement pursuant to 35 U.S.C. § 271(c) and/or (d), because with knowledge and intent to infringe the ’981 Patent, Amazon has both actively induced any such alleged third parties to directly infringe the ’981 Patent.”

Similar allegations have been made by the plaintiff with respect to the other Asserted Patents.

Plaintiff presented three claims for relief, each for the alleged infringement of the Asserted Patents.

In the prayer for relief, the plaintiff requested a judgment for declaratory and injunctive relief enjoining the defendants from using the Asserted Patents. The plaintiffs also requested an award for reasonable royalty damages and/or lost profits along with treble damages and supplementary damages. 

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